Following are a set of “best practices,” approved by the University Research Council in February 2001, developed to assure that research data are appropriately recorded, archived for a reasonable period of time, and available for review under the appropriate circumstances.
The University is accountable for the proper maintenance and availability of primary research data created or collected by university personnel. Sponsors of university research, federal and state oversight agencies, or journals and other colleagues in the field may need or be legally entitled to review primary research data well after publication or dissemination of results.
Researchers involved in group investigations have rights to access to data gathered by all members of the group.
The University may be required to review internally the adequacy and integrity of data if findings of University research are called into question, or if violations of research regulations, e.g. those protecting human subjects of research, are alleged. Moreover, the University must retain research data in sufficient detail and for an adequate period of time to enable appropriate responses to questions about accuracy, authenticity, primacy and to assure compliance with laws and regulations governing the conduct of the research.
Accurate and appropriate research records are an essential component of any research project. Both the University and the PI have responsibilities and rights concerning access to, use of, and maintenance of original research data. Except where precluded by the specific terms of sponsorship or other agreements, tangible research property, including scientific data and other records of research conducted under the auspices of Michigan State University, belongs to Michigan State University. The PI should be responsible for maintenance and retention of research data. Questions on the interpretation of this policy may be directed to the Research Integrity Officer.
Definitions and Applicability: These “best practices” should be adopted by all Michigan State University faculty, staff, students and other persons at Michigan State University involved in the design, conduct, or reporting of research at or under the auspices of Michigan State University. These practices should apply to all research projects on which those individuals work, regardless of the source of funding for each project.
Research data are defined as the recorded information, regardless of the form of the media on which it may be recorded, necessary to support or validate research findings. Included in the definition of research data are laboratory notebooks, as well as x-ray film, photographs, negatives and slides, print outs, video and audio tape, computers and computer data storage devices, and synthetic compounds, organisms, cell lines, viruses, cell products, cloned coordinates, plants, animals and spectroscope data, however recorded or preserved.
The PI is the signatory person who has scholarly responsibility for the conduct of the proposed research.
Where research is funded by a contract with Michigan State University that includes specific provision(s) regarding ownership, retention of and access to technical data, the provision(s) of that agreement will supersede these guidelines.
Ownership: The University’s claim to ownership and stewardship of the scientific records for projects conducted at the University, under the auspices of the University, or with University resources is based on both regulation (OMB Circular A-110, Sec. 53; 42CFR, Part 50, Subpart A) and sound management principles. Michigan State University’s responsibilities in this regard include, but are not limited to:
- Complying with terms of sponsored project agreements
- Ensuring the appropriate use of animals, human subjects, recombinant DNA, etiological agents, radioactive materials, and the like
- Protecting the rights of faculty, students, postdoctoral scholars, and staff, including, but not limited to, their rights to access data from research in which they participated
- Securing intellectual property rights
- Facilitating the investigation of charges, such as misconduct in research or financial conflict of interest
- Responding to legal actions involving the University related to research carried out under its auspices.
Collection and retention of research data: The PI is the custodian of the primary data, unless agreed on in writing otherwise, and is responsible for the collection, management, and retention of research data. The PI should adopt an orderly system of data organization and should communicate the chosen system to all members of a research group and to the appropriate administrative personnel, where applicable. Particularly for long-term research projects, the PI should establish and maintain procedures for the protection of essential records in the event of a natural disaster or other emergency.
Research data must be archived for not less than three years after the submission of the final project report or publication, whichever occurs last, with original data retained wherever possible. This should include prudent provision of off-site back up of electronic and hard-copy data. In addition, any of the following circumstances may justify longer periods of retention:
- Data must be kept for as long as may be necessary to protect any intellectual property resulting from the work
- If any charges regarding the research arise, such as allegations of misconduct in research or financial conflict of interest, data must be retained until such charges are fully resolved
- If a student is involved, data must be retained at least until the degree is awarded or it is clear that the student has abandoned the work.
Beyond the period of retention specified here, the destruction of the research record is at the discretion of the PI and his or her department or laboratory. The PI should make a permanent record describing the destroyed data and the destruction date.
To enable the University to meet its responsibilities related to stewardship of research data (as described above under “Ownership”), the PI should make all data available for review. This obligation continues even after the PI leaves the University.
The PI should assure that research data or copies thereof are made available for review by co-investigators in group research projects.
Records will normally be retained in the unit where they are produced. Research records must be retained on the Michigan State University campus or in facilities under the auspices of Michigan State University unless the Vice President for Research and Graduate Studies grants specific permission to do otherwise.
Transfer of data in event a researcher leaves Michigan State University: When individuals involved in research projects at Michigan State University leave the University, they may take copies of research data for projects on which they have worked. The PI must, however, retain original data at Michigan State University.
If a PI leaves Michigan State University, and a project is to be moved to another institution, ownership of the data may be transferred with the approval of the Vice President for Research and Graduate Studies and with written agreement from the PI’s new institution that guarantees 1) its acceptance of custodial responsibilities for the data and 2) MSU’s access to the data should that become necessary.